KI2 · Operation of a trading platform for crypto-assets
not held
An exchange where buyers and sellers are matched with each other through an order book. It requires operating rules, vetting of crypto-assets before admission to trading, resilient systems and public pre- and post-trade prices; dealing on own account is not allowed (Art. 76)64. It moves the company into capital Class 3 (€150,000)63.
Example activities: an order-book exchange like Kraken or Bitstamp; a regional exchange for tokens of domestic companies, as Adria Digital Exchange attempted35.
KI5 · Execution of orders for crypto-assets on behalf of clients
not held
The company executes a client's order on another trading venue, subject to a best execution obligation and an execution policy the client agrees to (Art. 78)64.
Example activities: limit and stop orders executed on external exchanges; brokering large (OTC) purchases across several exchanges to get the best price.
KI6 · Placing of crypto-assets
not held
Selling new tokens to buyers on behalf of the issuer. Before the agreement, the issuer must be informed of the placement method, fees, timing, price and target buyers, and conflicts of interest must be specifically managed (Art. 79)64.
Example activities: distributing a euro stablecoin or a domestic company's token to its own clients; tokenised bonds. In Croatia, Digital Assets (Bitcoin Store) holds it28.
KI7 · Reception and transmission of orders for crypto-assets
not held
The company receives an order from a client and passes it on to another party for execution. Orders must be transmitted promptly and accurately, without payments for order routing and without misuse of order information (Art. 80)64.
Example activities: a bank or exchange-office app that sends orders to a partner exchange; a corporate intermediary that collects orders from employees or clients.
KI8 · Providing advice on crypto-assets
not held
Personal recommendations to a client on what to buy or sell. It requires a suitability assessment (knowledge, objectives, financial situation), qualified staff, risk warnings and a suitability report (Art. 81)64.
Example activities: paid consultations for wealthier clients and companies entering crypto. General education, which Electrocoin already provides, is not advice because it is not a personal recommendation.
KI9 · Providing portfolio management on crypto-assets
not held
The company manages a client's crypto at its own discretion under an agreed mandate. The same suitability rules apply as for advice, plus quarterly reports to the client (Art. 81)64.
Example activities: ready-made portfolios (e.g. 70% BTC, 30% ETH) with automatic rebalancing; a crypto index for clients who do not want to pick for themselves.
KI10 · Providing transfer services for crypto-assets on behalf of clients
not held
Sending crypto from one address or account to another on behalf of a client. It requires a written agreement with the client covering procedures, security, fees and applicable law (Art. 82)64, along with the rule on tracing transfers (travel rule).
Example activities: sending crypto to an external wallet or to another user; paying merchants and employees in stablecoins through PayCek. Digital Assets and White Tech hold it28.
The badge colour is my assessment of how well each service would suit Electrocoin: green means a good fit with the existing business, yellow a moderate one, and orange a big step.